Frontier developer restricts or retaliates against safety whistleblowers

Carve AI-safety and legal-violation disclosures out of every NDA and policy, adopt non-retaliation, and run an internal safety-concern channel for covered employees.

Legal and HR own the employment and confidentiality templates (offer letters, NDAs, separation agreements, codes of conduct) and add an explicit carve-out stating that nothing in them stops a covered employee from reporting catastrophic-risk concerns or violations of the law to the authorities the statute names, or requires company approval first. Pair it with a written non-retaliation policy and an internal reporting channel for safety concerns (anonymous where required) with a documented triage and response procedure. Re-check every template when it is edited; the repository can hold the policy, the clause, and a CI check that each agreement template still contains the carve-out.

Where it goes: 12 repository artifacts, 14 user-facing text.

What reviewers look for: the carve-out clause present in every NDA, employment and separation template (not only the handbook), a non-retaliation policy, a reachable internal channel for covered employees to raise catastrophic-risk concerns with its procedure documented, and no clause requiring pre-approval before contacting an authority or penalising such disclosures.

Organizational control: the evidence is a kept record, its owner and its upkeep, not code.

Employee shall not disclose any Confidential Information to any third party, including any government body, without the Company's prior written consent.

Employee shall not disclose Confidential Information to any third party without the Company's prior written consent.

<!-- SAFETY-DISCLOSURE-CARVE-OUT -->
Nothing in this Agreement prevents Employee, without notice to or approval from the Company, from reporting to a government authority or through the Company's internal safety channel information Employee reasonably believes shows a specific and substantial danger to public health or safety from a catastrophic risk, or a violation of law. The Company will not retaliate against Employee for such a report.

Engineering guidance, not legal advice. Each provision below may add its own details (a cadence, a deadline, a required notice element): open it for those.